Transcript MBC Presentation - Massachusetts Biotechnology Council

Thomas Balf, Nexus Environmental Partners,
Policy Advisor to MBC
&
Susan Smits, Mabbett & Associates, Inc.
Co-Chair , Safety, Environmental and Facilities Committee
What are the Environmental,
Health and Safety Issues?
Cambridge Biosafety
Hazardous Material Storage
Chemical Policy/Safer Alternatives
Nanotechnology
DEP Toxics Reporting
Pharmaceuticals in Wastewater
DPH Medical Wastes
Pharmaceutical Waste
Greenhouse Gases
Process Safety/Vessels
Hazardous Wastes in Laboratories
Stormwater
We’ll Talk About:
 Trends and Themes (Tom)
 Two in Detail: (Susan)
 DEP Toxics
 DFS Process Safety
Mental stretch….& big picture look
#1
What used to be “Beyond Compliance”
is the New Compliance
 Carbon management
 Green Building requirements
 Pollution Prevention/Chemicals
Where were these issues 5 years ago?
Fed
State
Biosafety 3 & 4
Chemical Policy
NGO
X
X
X
DEP Toxics
X
DPH Medical
X
GHG Inventory
X
X
Haz Waste Labs
X
X
Haz Mat Storage
X
X
Nanotech
X
X
Pharma in WW
X
X
Pharma Waste
X
X
Process Safety
Stormwater
Local
X
X
X
X
X
#2 Collaboration  Recent Positive Experience:
 DEP
 DPHs
 Cambridge Public Health
 Role of trade assocs
 Concerns…
 Follow through in time of limited resources
 Innocuous language that becomes lever for more…
 Language written for enforcement and inspectors
#3
Chemical Policy – not this year, but…
 California – moving ahead aggressively
 Green Screen: assessment tools being developed
 NGOs: EPA, Cleangredients, Clean Production Action
MassDEP Industrial Wastewater
Toxics Discharge Reporting
 Purpose: identify/address significant environmental
problems from the discharge of toxics to sewers e.g
perchlorate case
 Mandatory toxics discharge reporting for 3,400 MA
facilities including LQGs and random facilities
 1900+ chemicals require reporting if discharged
 Facilities will receive a notification letter
 Web based reporting via eDEP
 Excel chemical inventory files can be partially
uploaded/imported.
MassDEP Industrial Wastewater
Toxics Discharge Reporting
Potential Impacts to MBC Members
 Potentially significant reporting burden
 Possible need to perform chemical inventory
and MSDS review
 Data may be publicly available
 Need for senior management official
certification
 Need to register/use eDEP system
State Fire Marshall’s Office
Process Safety Regulation
Purpose: Minimize risk to public from harmful
exposure due the unsafe processing of hazardous
chemicals.
Danvers Explosion
Draft 527 CMR 33 Hazardous
Material Processing
 Developing Process Safety Reg. and permit program
 Categories based on amount processed e.g. vessel size
1 = <1.5 gallons
2 = 1.5 – 15 gallons
3 = 15 – 60 gallons
4 = > 60 gallons
5 = RMP or OSHA Process Safety
 Increasing regulatory burden for each category
 Annual permit from Fire Department for Cat. 2 – 5
 All require emergency planning and post incident
analysis
 Category 4 = limited process safety hazard eval
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MBC
Tom Balf [email protected]
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Draft 527 CMR 33 Hazardous
Material Processing
 Exemptions include:
 NFPA Hazards if all < 2
- pH adjustment systems and water purification
- Boilers, emergency generators, etc.
- Collection of hazardous waste, SAAs, etc.
 Impacts to MBC Member Companies
 Increased regulatory burden
 Permit fees
 Fire Department inspections
- Possible need for consultant
MBC
Tom Balf [email protected]
15